xt7b8g8ffm32 https://exploreuk.uky.edu/dips/xt7b8g8ffm32/data/mets.xml Blair, Robert, 1857-  Hall, James M., 1855-1922.  Hall, Joe. 1919  books b922864b5752009 English Robert Blair : Whitesburg, Ky. Contact the Special Collections Research Center for information regarding rights and use of this collection. Sandlick Church (Letcher County, Kentucky). Primitive Baptists --Kentucky. Trial and decision of Sandlick Church property [Letcher County, Kentucky, 1917] / published by Robert Blair. text Trial and decision of Sandlick Church property [Letcher County, Kentucky, 1917] / published by Robert Blair. 1919 2009 true xt7b8g8ffm32 section xt7b8g8ffm32 
    
    
    
    
    
    
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PREFACE

The purpose of the publishing of this book is to give to its readers a more elaborate knowledge of the difference between The Old School or Primitive Baptist and the Old Regulars, as they denominate themselves.

The reader will find, by careful reading of this book, that all of the pleadings in the case of Joe Hall et al. against James Hall, et al., including the depositions of each side and the judgment of the Letcher Circuit Court, and the opinion of the Court of Appeals, as well as the briefs on each side.

This was a suit over the rights of the parties to the Old Sand-lick Church House, as to who was the rightful owner and entitled to the use of same.

Robert Blair, the publisher of this book, was one of the defendants in this case and gave his deposition therein, in which he explains the Doctrine of Election and Predestination, by the Primitive Baptist. He has been a member of the Primitive Baptist Church ever since the year 1879, and a minister therein for 35 years, and is now the moderator of the Sandlick Primitive Baptist Association.

The proceedings as given in this book is a complete record, as certified by the Clerk of the Letcher Circuit Court.   The reader v'vill find some few errors made by the stenographer in transcribing    he notes, some times the word "plaintiff" is used where it should be "defendant", and vice versa. 
   ARTICLES OF FAITH OF THE SANDLICK CHURCH

Adopted by the Sandlick Association in 1883, and by the Sandlick Church in the year 1885.

1. We believe in one true and living God    Father, Son and Holy Ghost   these three in one..

2. We believe that the Scriptures of the Old and New Testaments are the written word of God and the only rule of faith and practice.

3. We believe in the doctrine of election by grace.

4. We believe in the doctrine of original sin, and in man's impotency to recover himself from the fallen state he is in, by nature, by his own free-will and ability.

5. We believe that sinners are called, converted, regenerated and sanctified by the Holy Spirit, and all who are thus regenerated and born again by the spirit of God shall never fall finally away.

6. We believe that sinners are justified in the sight of God, only by the imputed righteousness of Jesus Christ.

7. We believe that the baptism, the Lord's Supper and feet-washing are ordinances of Jesus Christ and that true believers are the only proper subjects of these ordinances, and we believe the only true mode of baptism is by immersion.

8. We believe in the resurrection of the dead and a general judgment, and that the joys of the righteous and the punishment of the wicked will be eternal.

9. We believe that no minister has a right to administer the ordinance except such as are called and come under the imposi'ior of hands by the presbytery. 
    
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   AUTOBIOGRAPHY OF ROBERT BLAIR

I was born February the 9th, 1857; raised by poor parents, who had ten other children, two of whom were younger than I, this affaorded me very little chance to acquire an education, as we had to labor for our support, and the common school terms being so short and the distance from our home to school being near five miles. I grew up to manhood and took up the blacksmith trade, and followed it for about twelve years, during the time I began to attend school and study law, and was admitted to the bar to practice in May, 18      . I was married to Rachel Fairchild on the 13th day of April, 1878, and in the following spring, the Lord as I hope, revealed to me His spirit, and when this was done, I could see by His spirit, that I was corrupt, lost and an undone sinner, and my portion was with the Devil and his angels, in the lake of fire and brimstone, and everything that my eyes beheld seemed to witness my condemnation, and to say the lake is good enough for you. But alas! To my surprise, when I had come to the conclusion, and verily believed that I had the dreaded disease,   Consumption, (of which many of my relatives had died,) and I could not see any

way of escape, but must shortly leave this world; on the-

day of July, 18-, when one of my cousins had died with the

disease above mentioned, and I went to the funeral with the load of sin and corruption upon me, weighting me down to Hell, and for this reason, I could not stay at the house where the corpse was, so I thought I would go upon the Graveyard Hill, but when I got up there, the burden was so great that I believed that it was natural death preying upon me, ("I will lead them in a way that they know not, and in paths therein that they have not known.") and the very countenance of the friends who were digging the grave, the grave, and everything around me were still witnessing my condemnation, so something seemed to say to me, "Go to yon shade tree," (which stood about thirty yards from the grave,) so I went and sat down under it, and there bid my dear wife and child (as I only had one child at that time,) father, mother, brothers and sisters, and all things in this world, Farewell, verily believing in a very few moments that I would be dead, and condemned to the lake that burns with fire and brimstone, and there seemed to come a bounding in my heart, and a still voice which said, "Arise and go yonder,"   (meaning the grave.) And the first thing I knew, I was upon my feet, going, and when I came to the grave, there seemed to be no bottom to it, to me the earth seemed to open her mouth to recive me for the lake of fire and brimstone, and the last thing I remembered was as I turned to go back toward the bush again, (which was in a western direction from the grave,) I heard a voice behind me in the midway of the air, which said, "Behold the Lamb of God, that taketh away the sin of the world." This turned me right-about-face, and when I was turned I saw in the east, Christ with a cloud of witnesses with him, coming in the direction of where I was, this was the most beautiful sight that I ever beheld. Ah, how I wanted to embrace him in my amis, but alas, He vanished out of my sight, and gone was all of my guilt and fear, the load of corruption that I had so long been carrying, was taken away from me, and I was perfectly cured of my dreaded dis-eace of consumption, that I thought I was dying with.   Now I 
   was a new creature in a new world, and was rejoicing and praising the great name of Jesus our Savior. And while I was thus employed, the spirit directed me to the Primitive Baptist Church at Sandlick, in Letcher County, Kentucky., the history of which we J

will describe more fully in the following pages.   On the-day

of- 1879, as I hoped, the Lord added me to the church, 1

was baptized the following day by Eld. B. E. Caudill, (who was known as Colonel B. E. Caudill,) and who then lived in the State of North Carolina, but was visiting his people in Letcher County, Kentucky. When I was baptized, I thought all of my troubles were done, and I would have no more of them. But alas! This was just the beginning of trouble, for the burden of the Word of the Lord fell upon me, and I was tossed to and fro, and at times would find myself preaching as though I was in the presence of a congregation, that is, my mind would be exercised, yet, I knew I could not preach the Gospel of JesusChrist, for I was too ignorant, and had no delivery of speech, and I determined never to try such a thing. So the burden grew heavier, until one day when I was in the field plowing, preparing to plant corn, when I was carried out in the spirit, and I heard a noise and looked. And Behold! I saw the son of man as I saw him on the Graveyard Hill, when I was healed of that dreaded disease, except the angels and witnesses that were with him had trumpets, and they came to where I was and put one to my inouth, and it made the sweetest music, just like all the rest that was with him, and when I came to myself, so as to realize what was going on about me, the little daughter of William Greene was down at the lower side of the field calling for me to come to dinner, and the mule I was plowing was standing out in the field where I suppose I had left him, and I was outside of the field, up in the woods. How, and by what menas I got there has always been a mystery to me.

Shortly after this time I decided that I would make the effort to preach in public, and about this time I dreamed that I was traveling, and I came to a bottom of timber, all full grown, and in that bottom the foundation of a new house was laid, and the logs for the house fresh hewn, were scattered over the mountains. When 1 approached the foundation of the new house, I discovered that the path I was traveling went through the house, and I pursued my journey and when I got into the foundation of same, the devil got after me, and I worried with him for some time when at last 1 thought of the Lord, and when I could think of the Lord, the devil would vanish away. I dreamed this dream seven nights in succession, and each time the house was some nearer completed, until the last night I came to see it, it was finished, all but the chimney, and it was built up to the coping on the outside of the house, and the path went over the top of the house, and as I stepped over the top of the chimney, I thought this is one time I will get through without the devil getting after me. As this thought came to me, the devil reached up ont of the chimney, as I brought my last foot over the top of it, he caught me by the foot and held me for some time. I was worrying with him when the thought came to me .Why don't you think of the Lord, like vou alwavs did before." When I thus thought, he was gone and I awoke. The last time 1 dreamed this was on Friday night before the first Saturday in the month of      -_. 18_ 
   ELDER J. M. HALL

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BIOGRAPHY OF JAMES M. HALL

Eld. James Monroe Hall was born January 22, 1855, at Viper, entucky, where he resided all his life. He was united in matri-ony with Miss Louemma Jane Hill, September 26, 1875. He lited with the Primitive Baptist Church about the year 1877, lortly afterwards he was ordained to the full functions of the >spel ministry. He was known to be a great preacher of the rimitive Baptist doctrine and was highly esteemed among them.

He was of a kind congenial spirit, which gained for him the iendship of many who knew him.

He was elected as a member of the lower House of the Legis-ture in the year 1897.

He took an active hand in educational and all movements for >od. After the death of his first wife he was married to Miss rtha Godsey.

He was stricken with Paralysis on August 31,1922, and passed his reward September the 8th, 1922.   (The voice of Jesus) Veil done, thou good and faithful servant."   His last words were, )ver there is life everlasting, and I am going up there."

The funeral services were conducted by Elders Thomas Kelly id J. H. Hudson, both of whom had been constant companions, id whom he greatly admired, on the following day.

His first wife was a consistant christian woman, a member of e Methodist Church, and his last wife, was a member of the Prim ve Baptist Church.

He belonged to the Sandlick Association, and which he served the capacity of clerk for a number of years, and later chosen

oderator of the Association in which capacity he was serving the time of his death. He was also serving the Sandlick Church moderator at the time of the filing of this long and wearisome

se, and this is the reason why he was made one of the defendants this action. 
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CREDENTIALS OF L. F. ADKINS Bf

Know all men by these presents, that on the 15th day of Aug-ar Bal ust, 1896, the Regular Primitive Baptist Church, called Sandlick,0j,nt,v situated in Letcher County, Kentucky, met in council with the presbytery for the purpose of ordaining Brother Lewis F. Adkins ^ to the full functions of the gospel ministry, and after due deliber-e^arat ation proceeded to ordain him by prayer and laying on of hands by^g' the Presbytery.   Now, therefore, be it known that Elder Adkinsoft(j'en( is a brother in good standing with us and we recommend him to 1!n<01.].y ( Regular Primitive Baptist everywhere. ;a|A

The Church, the Presbytery and the above named Elder lx>'Wjons the doctrine of special atonement by Jesus Christ for the elect ot^,j.s ( God, who are predestinated unto the adoption of children by Jesting p Christ to himself in time, and thenceforth kept by the power nf (; '., unto glory. reek I

Elder Joseph Hall, ear 18

Elder S. C. Caudill, ie. int

Elder J. A. Craft,    doc Joseph Blair, iiat do

Jesse Adams, laNev Deacons.   t wel

Presbyterv 3timI ' ^gers

The above Credentials of Elder Lewis Adkins, is publish. "d for the purpose of showing the doctrine that Elder S. C. CaudiJj 1, was identified with, even after the division in May, 1896.   SanvJ fV~ being a true copy of the record made by him. .]l0

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   11

Brief sketch of the history of the separation of the Old Regu-ofAug-ar Baptists from the Primitive Baptists in this section of the

indlick.otmtrv.

ith the %

Adkins \^ js necessary to give here a short sketch or history of the lelibei'-apa..atjon 0f (.he q1cj pkegUjai. Baptists from the Primitive Bap-

'ahv     * '   *n ^'ie year 1893, *ne Sandlick Association was in corres-*   '{lsojndence with the New Salem Association, as well as the Three 110 *   orks of Powells River Association of Primitive Baptist, and the _     lates Creek Association and the Union Association.   These asso-,er h(,lt{ations were in correspondence with each other, and the Three elect ofc^j.j, 0|' Powells River Association was in correspondence with y J^%e Powells Valley Association, the Washington Association, the '   *    Tates Creek Association, the Union Association and the Stony reek Association.   When the New Salem Association met in the ear 1898, Elder Thomas Hopkins, of that Association preached le introductory sermon, and preached the doctrine of Armin-inism, and at the close of the discourse, declared that was he doctrine of the New Salem Association, and all that believed hat doctrine, preached by him, they were welcome to a seat in ie New Salem Association, and those whe did not believe it were ot welcome to a seat in the association.   Then the messengers . atired to the house and after holding- a conversation with the mes       angers from the various associations to-wit:   Elder S. C. Caudill, nd Robert Blair, from the Sandlick Association; Elder D. II. Riner ublisli'n(j 0t]iers from the Three Forks of Powells River Association: Caudill tiie messengers from the Mates Creek and Union Associations,       Sanij1(j j.jie severai messengers from the churches of the New Salem, ho refused to be seated with it because of the declaration made . Elder Hopkins, all of the corresponding Associations withheld leir correspondence and returned home except Calvin Swindle, ho was a member of the Three Forks of Powells River Associa-on, took a seat with the New Salem Association, and preached in ie stand on Sunday, as their records show.   Then in August 1894 ie Three Forks of Powells River Association met with the church t Gladeville, Virginia, and when the house was called to order by ie moderator, and the letters were handed in, as was the custom, hen the clerk read the letter presented by the Little Zion Church, ' which Eld. Calvin Swindle was a member, and was a messenger ) the association, the;e was an objection to the letter from the Siurch, in that she had deviated from the orthodox principles of ie Primitive Baptist by Elder Swindle taking a seat in the New ilem Association, as a transient minister, and when called upon jout it, he denied taking a seat with them as a transient minister, id preaching on their stand.   After his denial, Elder Robert Blair id Wilson Church presented one minute each of the New Salem ssociation, showing that he was received as a transient minister, hen after some discussion between Elder Calvin Swindle and imes Walton, a messenger of Powells Valley Association, the ssociation then by a move and second, withdrew from the Little 
   12

Zion Church until she had set herself in order.

On Friday before the third Saturday in September, the Union Association convened with the Mt. Pleasant Church in Dickenson County, Virginia, and Elder John A. Craft, the present moderator of the Association being absent, it was agreed that Joe Hall, the Clerk of the Association, was the one to call the house to order and read the letters with the view of seating the messengers, and after the letters had all been handed in, the clerk having to make up all the records, requested Elder Robert Blair to assist him in the reading of the letters, which he did, and the reading of the letters went on smoothly without any objection until the letter from the Union Church was read, which contained declarations of non-fellowship for certain doctrines which were in harmony with the doctrine of the Primitive Baptist, and there was an objection to receiv ing the letter and messengers because same showed on its face a radical departure from the orthodox principles laid down in the Articles of Faith, and the vote being taken, the letter and messengers were rejected and left the house, and some of the churches asked for their letters back and left the house. Then the association was organized by electing Elder Joe Hall moderator and J. L Holbrook clerk, and the business of the association was carried on in the usual manner.

This sketch of history is given for the purpose that the reader may have a full knowledge that the division of the Old Regular Baptist from the Primitive Baptist had nothing to do with the division of the Sandlick Church, and to show that after the division in the Sandlick Church, that the parties in the Sandlick Church had made reconciliation, and Elder S. C. Caudill was moderator of the Sandlick Church at the time of his death, and to show how they undertook to slander Elder C. C. Caudill after his death by instituting this suit to intimidate the members thereof, and to destroy the old Sandlick Primitive Baptist Church.

It was not the property of the Church that caused the defendants to withstand the plaintiffs, but the cause of Christ, and the integrity of the late S. C. Caudill.

We hope the reader will read this book prayerfully, and then decide for himself.

3 more I

lea< the edg the the bra the Plainl oundar aember i whicl 
   13

LETCHER CIRCUIT COURT

IN EQUITY

Toe Hall, W. G. Caudill, Sabina Caudill, William Ramey, Polly Ann Craft, Who Sue for Themselves and All Members of Sandlick Church, of the Regular Primitive Baptist Faith...........................PLAINTIFFS

vs. [PETITION IN EQUITY

Tames M. Hall, Robert Blair, Peter Adkins, S. G. Fairchild, David Sergent and Joseph Fairchild......DEFENDANTS

The Plaintiffs state that on the-day of-, 18   ,

:ertain persons whose names the Plaintiffs cannot now state, for he reasons hereinafter mentioned, met and assembled themselves ogether in one body for the purpose of establishing a church, vhich they called and denominated the Sandlick Church. This lame was given to the Church for the purpose of identifying it md the name was so selected because the place they met to wor-ihip was at or near the mouth of Sandlick Creek, on the North rork of the Kentucky River, which is now in Letcher County, Ken-ucky, and that at said meeting, the persons who had met duly nade and adopted an Article of Faith, which article of faith was educed to writing and expressed clearly the religious views of aid meeting, and this article of faith was what the Plaintiffs know nd call as the "Old Regular Primitive Baptist Faith," and that iter said article of faith was duly adopted and signed by the iroper parties, they thereupon proceeded to and did elect a pastor f said Church, whose name the Plaintiffs are now unable to give or the reasons hereinafter stated, and that said organization im-lediately began to and did hold regular meetings at stated times nd at the place hereinbefore mentioned, and thereby became a ixed and permanent organization, for the purpose of preaching he gospel according to the articles of faith adopted by them.

Plaintiffs state that on the-day of-, 18   , one

"ohn A. Caudill, who was a member of and believer of the said Jhurch, donated to the said Sandlick Church the following de-cribed lot of land for the purpose of erecting thereon a suitable hurch house, at which place the said Church as a body could meet nd hold its regular meetings.   Said lot of land is situated in ..etcher County, Kentucky, near the mouth of Sandlick Creek and 3 more particularly bounded and described as follows, to-wit: Beginning at Murphys Branch in the edge of the road leading down the river from the town of Whitesburg, thence down the road N 77 W 8 poles to a stake with the edge of said road; thence N 18 E 15 poles to a stake; thence East four poles to a stake in the Murphy Branch; thence with said branch S 18 E 4 poles to a stake in said branch; thence S 2% W8 poles to a stake in said branch; thence S 22 W 4 poles and 12 links to the beginning. Plaintiffs say that after the said donation and gift of the said oundary of land to the members of the said Sandlick Church, the lembers thereof proceeded to and did erect a church house, and l which building the said Church then and thereafter hold its reg- 
   14

ular church services for a period of years, and that on the 10th day of May, 1873, the said John A. Caudill died without having made any deed to said Church, and that after the death of the said Caudill, by proper orders and proceedings had in the Letcher Circuit Court, one S. R. Adams, as Commissioner of said Court, was directed to and did make and execute a deed to the said boundary of land, given and donated to the said Church by the said John .A. Caudill, and that after this deed was executed the said Sandlick Church proceeded to and did build a more commodious building on said lot, and continued to use and occupy and control said building as its designated place of worship for several years thereafter.

Plaintiffs say that on and about the 16th day of May, 1896, and at one of the regular church meetings of the Sandlick Church, held and convened at the church house hereinabove described, the Defendants, Joseph Fairchild, Robert Blair, S. G. Fairchild and ont Peter Adkins, absented themselves from the Sandlick Church and left the church house while the business of the Church was beinj conducted and went to another point and place and organizes themselves into what they call and term a body and also named that body the Sandlick Church, and the said S. G. Fairchild being at the time Clerk of the Sandlick Church, took away with him the Church Records, containing the said Article of Faith and the book in which all the members of said Church were enrolled, and all the records and minutes and proceedings of said Church and thereby Plaintiffs and their members, and all the members of said Church, have been and are now deprived of the use and benefit of the records of said Church, and for that reason the Plaintiffs are now unable to state and to set out fully the names of the members of the original Sandlick Church in detail, but here allege that they were numerous and contained a large membership, and that shortly after the taking of said church records by the said S. G. Fair-child, the said Fairchild and his co-defendants herein, obtained without the consent of the Plaintiffs or any of the members of the original Sandlick Church, Plaintiff's said church house and lot hereinbefore described, and that these Plaintiffs understood, believe and charge the taking of said possession by the Defendants was wrongful, without right or authority on the part of said Defendants, and that said Defendants met with other persons, whose names these Plaintiffs cannot now give, and that they now have and hold the possession of said church house and lot and the rec-ords of the original Sandlick Church, all of which, are as Plaintiff believes, wrongfully on the part of the Defendants, and without right or authority vested in them and that said Defendants and I other persons acting with them, whose names the Plaintiffs cannot now give, now hold the possession of said property and absolutely refuse to permit the Plaintiffs and other members of said Church to use or occupy for all or any church purposes, the said building; and lot, and the Plaintiffs and other members of said Church are I thereby totally excluded from the use or occupancy of said Church and church property.

The Plaintiffs state that they and the other members of the or-1 lginal Sandlick Church now and have at all times since their membership, have held to, promulgated and believe in said Church as I originally established and the Articles of Faith, made and estab- 
   15

lished at the time said Church was organized, and that they have at all times held to such faith, and have not parted therefrom and are therefore the legally constituted body of said Sandlick Church and are, as they believe, entitled to the records and proceedings of said Church and the property owned by it.

Plaintiffs say that the Defendants and their followers, who are very few in number, have departed from the original Article of Faith and now, and have at all times since their departure, promulgated and preached and held out to the public an entirely new doctrine, which was not embraced within the original Article of Faith of the Sandlick Church, and having thereby and by their acts, absented themselves from the said Sandlick Church, and that they are not now entitled to use or to occupy the church house, lot or building, or to have in their possession the records of said Church.

Plaintiffs say that by reasons of the acts hereinbefore stated .and by reason of the fact that they have not before them the church records of the Sandlick Church, that they are unable to know or to say whether or not there is upon said record any order or proceeding wherein or whereby the said Church had any Trustees in which the title to the land and property vested upon the execution of the deed by S. R. Adams as Commissioner of the Letcher Circuit Court, but that said deed does not mention the name or names of the persons as Trustees of said Church, and therefore they are of the opinion and believe and here charge that said Church does not now have any regularly constituted or appointed Trustees, and therefore they ask that this Court appoint of the same faith and order as the original Sandlick Church, measured as a standard by the Articles of Faith adopted by that Church in the beginning, and that for the purpose of determining this fact, the Defendants be required to produce in open Court the Church be adjudged the absolute possession and control of said records of the original Sandlick Church, and especially the Articles of Faith governing said Church.

The Plaintiffs say that inasmuch as th emembers of the said Sandlick Church are numerous and their names not definitely and well known to them, they now ask that they be permitted to bring and prosecute this action for and on behalf of all the members of said Sandlick Church.

Wherefore the Plaintiffs pray that this Court immediately appoint three trustees to act for and on behalf of the said Sandlick Church, and that said Trustees or this Court take immediate control of the records of said Sandlick Church and the house and lot hereinbefore described, and direct its management until final hearing of this case, and Plaintiffs and other members of the Sandlick Church Records and the house and lot hereinbefore described, and that they and their successors be adjudged the beneficiaries thereof, and they would ever pray. They pray judgment for their cost and all other proper relief.

R. MONROE FIELDS,

D. D. FIELDS, Counsel for Plaintiffs.

W. G. Caudill says that he is one of the Plaintiffs in the foregoing petition and that the statements contained therein are true.

W. G. CAUDILL. 
   16

Subscribed and sworn to before me by W. G. Caudill, this the 6th day of July, 1915. D. I. DAY, J. P.

W.

LETCHER CIRCUIT COURT G. Caudill, Etc.............................................................................

..Plaintiffs

[Separate and Joint Answer and Counter Claim of vs. [Robert Blair, Peter Adkins, S. G. Fairchild and [David Sexton.

Robert Blair, Etc...............................................................................................Defendants

The Defendants, Robert Blair, Peter Adkins, S. G. Fairchild and David Sexton for their separate and joint answer and counter claim herein comes and not waiving- their motion to require the Plaintiffs to make more specific their petition herein as to the doctrine the Defendants aie promulgating and preaching that is not contained in the Articles of Faith, but relying and insisting on same, says it is false and untrue and deny that on or about the 16th day of May, 1896, the Defendant or either of them at said time a; one of the regular church meetings of the Sandlick Church held and convened at the church house described in Plaintiff's petition, or at any other place or time, absented themselves or either of them left the Sandlick Church House while the business of the Church was being conducted and went to another point or place and organized themselves into what the Defendants called and termed a body, which they called the Sandlick Church, denies that they or either of them organized any body, denies that the Defendant, S. G. Fairchild, took away with him all the records and proceedings of said Church, denies that by the reason of any taking of said record has deprived all or any member of said Church of the use and benefit of the records of said Church.

The Defendants deny that after the taking of the records of the Church by the said S. G. Fairchild, the said Fairchild and his co-defendants obtained without the consent of any of the members of the original Sandlick Church, the house and lot described in Plaintiff's petition herein, denies that said house and lot is the property of the Plaintiffs or either of them, denies that the taking' of the possession by the defendants of said house and lot and records were wrongfully, without right or authority on the part of I the Defendants or either of them; denies that they or either of them now have and hold the possession of said church house, lot I or the records of the original Sandlick Church wrongfully on the: part of the Defendants or either of them; denies that they or eitli-j er of them holds the possession of same without right and author-1 ity vested in them; denies that the Defendants and those acting with them now hold possession of said property and absolutely refuse to permit the members of said Church to use or occupy for all I or any church purposes the said building or lot; denies that any I member of said Church are thereby totally excluded from the use;; or occupancy of said church house and church property; denies that the Plaintiffs or any one acting with them are members of I the original Sandlick Church; denies that the Plaintiffs or either! of them are members of the original Church under the originalI Articles of Faith on which the said Church was constituted and?: which was adopted by the sai